ManuBalboa
04-20-2011, 06:43 PM
http://www.huffingtonpost.com/2011/04/20/mark-zuckerberg-wears-tie-jeans-obama-interview_n_851746.html
Jokes and jokes and jokes. Meanwhile, Facebook & Google use the "Double Irish" loophole to save billions in tax money. :lol America
From Wikipedia (http://www.wikipedia.org/), the free encyclopedia
The Double Irish Arrangement is a tax avoidance (http://www.facebook.com/pages/w/110102695686412) strategy that U.S. based multinational corporation (http://www.facebook.com/pages/w/109374872422097)s use to lower their income tax (http://www.facebook.com/pages/w/109370642415053) liability. The idea is to use payments between related entities in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on the fact that Irish tax law (http://www.facebook.com/pages/w/140375845989438) does not include effective transfer pricing (http://www.facebook.com/pages/w/114697051878724) rules.
Overview
Typically, the company arranges for the rights to exploit intellectual property (http://www.facebook.com/pages/w/112110308800333) outside the United States to be owned by an offshore company. This is achieved by entering into a cost sharing agreement (http://en.wikipedia.org/wiki/Transfer_pricing%23Cost_sharing) between the U.S. parent and the offshore company, in the terms of U.S. transfer pricing rules. The offshore company continues to receive all of the profits from exploitation of the rights outside the U.S., without paying U.S. tax on the profits unless and until they are remitted to the U.S.
It is called "The Double Irish" because it requires two Irish companies to complete the structure. The first Irish company is the offshore company which owns the valuable non-U.S. rights. This company is tax resident (http://www.facebook.com/pages/w/137309346289416) in a tax haven (http://www.facebook.com/pages/w/114995731848319), such as Bermuda (http://www.facebook.com/pages/w/107662725923561) or the Cayman Islands (http://www.facebook.com/pages/w/112724198741571). Irish tax law provides that a company is tax resident where its central management and control is located, not where it is incorporated, so that it is possible for the first Irish company not to be tax resident in Ireland. The first Irish company licenses the rights to a second Irish company, which is tax resident in Ireland, in return for substantial royalties or other fees. The second Irish company receives income from exploitation of the asset in countries outside the U.S., but its taxable profits are low because the royalties or fees paid to the first Irish company are deductible expenses. The remaining profits are taxed at the Irish rate of 12.5% (http://www.facebook.com/pages/w/139881336044966).
brb bitching about corporate greed then receiving campaign money from said corporate greed
Jokes and jokes and jokes. Meanwhile, Facebook & Google use the "Double Irish" loophole to save billions in tax money. :lol America
From Wikipedia (http://www.wikipedia.org/), the free encyclopedia
The Double Irish Arrangement is a tax avoidance (http://www.facebook.com/pages/w/110102695686412) strategy that U.S. based multinational corporation (http://www.facebook.com/pages/w/109374872422097)s use to lower their income tax (http://www.facebook.com/pages/w/109370642415053) liability. The idea is to use payments between related entities in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on the fact that Irish tax law (http://www.facebook.com/pages/w/140375845989438) does not include effective transfer pricing (http://www.facebook.com/pages/w/114697051878724) rules.
Overview
Typically, the company arranges for the rights to exploit intellectual property (http://www.facebook.com/pages/w/112110308800333) outside the United States to be owned by an offshore company. This is achieved by entering into a cost sharing agreement (http://en.wikipedia.org/wiki/Transfer_pricing%23Cost_sharing) between the U.S. parent and the offshore company, in the terms of U.S. transfer pricing rules. The offshore company continues to receive all of the profits from exploitation of the rights outside the U.S., without paying U.S. tax on the profits unless and until they are remitted to the U.S.
It is called "The Double Irish" because it requires two Irish companies to complete the structure. The first Irish company is the offshore company which owns the valuable non-U.S. rights. This company is tax resident (http://www.facebook.com/pages/w/137309346289416) in a tax haven (http://www.facebook.com/pages/w/114995731848319), such as Bermuda (http://www.facebook.com/pages/w/107662725923561) or the Cayman Islands (http://www.facebook.com/pages/w/112724198741571). Irish tax law provides that a company is tax resident where its central management and control is located, not where it is incorporated, so that it is possible for the first Irish company not to be tax resident in Ireland. The first Irish company licenses the rights to a second Irish company, which is tax resident in Ireland, in return for substantial royalties or other fees. The second Irish company receives income from exploitation of the asset in countries outside the U.S., but its taxable profits are low because the royalties or fees paid to the first Irish company are deductible expenses. The remaining profits are taxed at the Irish rate of 12.5% (http://www.facebook.com/pages/w/139881336044966).
brb bitching about corporate greed then receiving campaign money from said corporate greed